We understand that your privacy is important to you, and we are committed to protecting your privacy and the personal information you provide as you access our services, and we recognise that you have an interest in how we collect, retain and use information about you.
1. Introduction
This Privacy & Cookies Policy applies to all the products and services offered by MindFolio Ltd, except where otherwise noted. We refer to those products and services collectively as the “services” in this policy. Use of this website, or any other service indicates your acceptance of our Privacy Policy. References to “data” in this Privacy Policy will refer to whatever data our services collect, whether it be survey responses, data collected in a form, data collected on our ChatLab® platform, or data collected by our website – it’s all your data! Reference to personal information or just information, means information about you personally that we collect or for which we act as custodian. You may always submit concerns regarding our Privacy Policy or our privacy practices to privacy@mindfolio.com.
2. Information we collect
2.1 Who are “you”?
We refer to “you” a lot in this Privacy Policy. To better understand what information is most relevant to you, see the following useful definitions.
- Respondents: You have received a survey or form, or have registered with a ChatLab® platform created by MindFolio Ltd.
- Website Visitor: You are just visiting our website.
2.2 Information we collect about you
- Contact information (for example an email address): You might provide us with your contact information in submitting a request on our website, registering with ChatLab® or asking us a question about one of our surveys.
- Socio-demographic information: You might provide us with information such as your age, gender, income, residence, etc. in response to one of our surveys or other services.
- Usage information: We collect usage information about you whenever you interact with our websites and services. This includes which webpages you visit, what you click on, when you perform those actions, what language preference you have, etc.
- Device and browser data: We collect information from the device and application you use to access our services. Device data mainly means your IP address, operating system version, device type, system and performance information, and browser type.
- Referral information: If you arrive at a MindFolio website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
3. How we use the information we collect
3.1 Respondent
We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in this Privacy Policy. We have taken procedures to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used. We ensure that personal information of all users is respected and protected.
A) Cookies (to include page tags)
We collect information using cookies when you take a survey. These cookies are used to ensure that the full functionality of our survey service is operational, to ensure the survey operates appropriately and optimally. For more information please read our Cookies section below. After completion of a survey, in most cases, you will be re-directed to the website of our ‘panel provider’ and treated as a website visitor of this site, where other cookies may be used.
Examples: We use cookies to ensure a respondent can only take a survey once (where the creator of a survey has set this function) and to track completion rates of surveys.
B) Contact information
As a survey Respondent, we only use contact information to respond to an enquiry which you submit to us.
Examples: Our support team may use your email address to communicate with you if you have contacted us about a survey or form you received, but we will not send marketing to you unless you have otherwise opted-in to marketing.
C) How you use our services (applicable to survey Respondents only).
We use information about how you use our services to improve our services for you and all users.
Examples: We collect information based on the questions you answer. This data will be aggregated and anonymized so we can examine patterns in terms of respondent preferences when submitting responses (see further below in Information for Survey Respondent section). We collect and use all this data for our legitimate interests like helping to understand industry trends, to improve the experience for respondents (so that questions are easier to answer), and to help improve the completion rates on
surveys/forms.
We will also use usage information such as the type of survey, form, questionnaire or application that you answered.
D) Device and browser data
We record the device and browser type as well as operating system when using our services. We also infer your geographic location based on your IP address.
Examples: We collect this to ensure that service experience works well across all possible devices and to infer geographic location to produce aggregated data around Respondent location trends. Note however, that we do not collect precise GPS co-ordinate location. We just infer location from the IP address.
F) Machine learning
In analysing survey response data, we may use machine learning techniques. In such instances, personally identifiable information is never used. As always, all data is aggregated and anonymised before any analytical process are undertaken. More detail on this can be seen in the ‘Use of survey responses’ section.
G) To manage our services we will also internally use your information and data, for the following limited purposes:
- To enforce our agreements where applicable
- To prevent potentially illegal activities
- To screen for and prevent undesirable or abusive activity
H) Legal uses
To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
3.2 Use of survey responses
Responses to MindFolio Ltd surveys are controlled and managed by MindFolio Ltd. When we do analysis of response data we only do so once we have ensured the anonymity of individual respondents (by aggregating and anonymising the data). Our goal is to understand customer behaviour and industry trends while maintaining the confidentiality and privacy of responses. We use the information that you provide us via our surveys to produce and deliver requested products, services and reports. MindFolio uses tools, methodologies, and automated processes to analyse survey responses, which in turn helps us to:
- Aggregate response data and activity: We will aggregate responses, activity and behaviour of Respondents so that we can identify industry trends, build product features that optimize responses, make recommendations and provide guidance on which products and services work best in different scenarios.
- Extract and analyse usage patterns: By understanding response data and Respondent interaction in different types of surveys we can:
— Improve our services and ease of use: for example, we might identify when respondents prefer multiple choice versus open text questions and make predictive response suggestions when certain question types are selected. We might also use this data to help improve analysis of responses.
— Improve user experience (for example, by collecting and using device and browser information from Respondents to improve how our survey service operates on those devices and in those browsers).
— Identify insightful data trends (which never identifies any individuals).
3.3 Visitor
We process personal data about you, where:
- You have consented or;
- MindFolio Ltd has legitimate interests of:
— Improving service experience; and
— Developing new products and service features
In each of the instances where we describe how we use your data in this Privacy Policy, we have identified which of these grounds for processing we are relying upon. When you have consented we collect and use the following information about you:
A) Contact Information
We use contact information to respond to your enquiries, send you information as part of our services, and send you marketing information (as long as you have agreed to this at the point of providing your information and for as long as you do not opt-out).
Examples: We provide your email address to a member of our marketing team who will contact you if you submitted an enquiry. You will also receive marketing communications from us if you have consented to this at the point where you provided your information. We will always provide you with the means to opt-out of this marketing at any time.
B) How you use our services
We use information about how you have interacted with our websites to improve our website services for you and all users.
Examples: We collect information about the webpages you have visited and your activity on our sites. We collect this information so that we can track the most visited and most useful parts of our website to identify what are our most popular services.
C) Device data
We use device data both to troubleshoot problems with our service and to make improvements to it. We also infer your geographic location based on your IP address.
Examples: We collect device and browser information from you to troubleshoot website functionality issues and to fix bugs.
4. Information you share
Some of our services let you share information with others. Remember that when you share information publicly, it can be indexable by search engines. Our services provide you with different options on sharing and deleting your content but we cannot delete content from search engines, so you need to be careful about information you make public.
5. Information we share
We do not share your information or data with third parties outside of MindFolio Ltd. We enter into confidentiality and data processing terms with partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards and we regularly review these standards and practices.
Both surveys and the ChatLab® platform created by MindFolio are made using 3rd party software. The software providers have no ownership of any data collected. When completing a survey or using the ChatLab® platform, you may be required to submit certain contact information and enter login details. These details will only be used to send occasional updates and survey invitations, but never shared with others for marketing purposes. Any analysis of data will be anonymised, and any contact information removed. If you would like further information on the privacy policy and terms of service for these providers, please contact: privacy@mindfolio.com.
We also have to share information or data in order to:
- Meet any applicable law, regulation, legal process or enforceable governmental request
- Enforce applicable policies, including investigation of potential violations
- Detect, prevent, or otherwise address fraud, security or technical issues
- Protect against harm to the rights, property or safety of our users, the public or to MindFolio and/or as required or permitted by law
6. Cookies
This part of the Policy explains how and why Cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) may be stored on and accessed from your device when you use or visit any website, app or survey that posts a link to this Policy (collectively, “services”).
By continuing to browse or use our Sites, you agree that we can store and access Cookies and Other Tracking Technologies as described in this Cookie Policy. Please see below for details on each of the types of Cookies we use.
How do our Sites use Cookies and Other Tracking Technologies?
Cookies are small bits of data we store on the device you use to access our services so we can recognise repeat users. Each cookie expires after a certain period of time, depending on what we use it for.
MindFolio uses Cookies and Other Tracking Technologies to identify you, remember your preferences, and to track your use of our Sites. We also use Cookies and Other Tracking Technologies to control access to certain content on our services, protect services, and to process any requests that you make of us.
What Cookies do we use?
Below we list the different types of Cookies that may be used on the Sites. Our services use both:
- First-party Cookies: “First party Cookies” are Cookies that belong to MindFolio and that MindFolio places on your device.
- Third-party Cookies: “Third-party Cookies” are Cookies that another party places on your device through our Site.
A) Persistent Cookies
We use persistent Cookies to improve your experience of using the Sites. This includes recording your acceptance of our Cookie Policy to remove the Cookie message which first appears when you use the Sites.
B) Session Cookies
Session Cookies are temporary and deleted from your machine when your web browser closes. We use session Cookies to help us track internet usage.
C) Required or Essential Cookies
Certain Cookies are necessary in order for the Sites to operate correctly. These Cookies, for example, let us recognize that you have created an account and have logged into that account to access service content. They also include Cookies that enable us to remember your previous actions within the same browsing session and secure our services.
D) Functionality Cookies
These Cookies are used to enable certain additional functionality on our services, such as:
- Gathering metrics about your survey taking experience: For example, we will collect data about the number of clicks it took Respondents to complete a survey, whether they left and returned to a survey, whether they skipped parts of a survey and how long it took to complete the survey and other details about the survey taking. However, this information is collated and kept at an aggregated and anonymized level only.
- To improve our services: We use cookies to measure your usage of our services and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services (it helps us focus on the parts of the service you seem most interested in) and optimise the content we display to you (which may include marketing content)
E) Preference Cookies
Preference Cookies collect information about your choices and preferences, and allow us to remember language or other local settings and customise services accordingly.
F) Analytics Cookies
These Cookies are used by us or third-party service providers to collect information about your use of our services, and enable us to improve the way it works.
- Google Analytics: We have implemented on our services certain Google Analytics features to assess items such as site traffic and page visitation frequency. Visitors to our websites may opt out of certain types of Google Analytics tracking, customize the Google Display Network ads by using the Google Ad Preferences Manager and learn more about how Google serves ads by viewing its Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on. If you subscribe to a newsletter or otherwise register with our servics, these Cookies may be correlated to you. These Cookies include, for example, Google Analytics Cookies.
You can choose to remove or disable cookies via your browser settings.
7. Data Retention
MindFolio retains personal data, as necessary, for the duration of the relevant business relationship. We may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, recruitment, or comply with our information management policies and schedules. If you request that we delete your personal data, MindFolio will make reasonable attempts to delete all instances of the information in their entirety.
8. Safety of Children / Minors
MindFolio takes children’s privacy seriously and we do not knowingly collect any information regarding children or minors. Our services are not intended for and may not be used by minors. “Minors” are individuals under the age of 13 (or under a higher age if permitted by the laws of their residence). MindFolio Ltd does not knowingly collect personal data from Minors or allow them to take part in surveys. If it comes to our attention that we have collected personal data from a Minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact privacy@mindfolio.com.
9. International transfer of information
Because MindFolio is a global organisation, information collected from our services may be transferred from time to time to MindFolio offices or personnel located around the world, including our current offices and employees located in the US and Europe, and also to offices or personnel outside the European Economic Area. MindFolio’s services may be viewed and hosted from anywhere in the world, including countries that may not have laws regulating the use and transfer of personally-identifiable and private information. By using MindFolio’s services, you voluntarily consent to such trans-border transfer and hosting of such information.
10. Changes to our Privacy & Cookies Policy
Please check this page periodically for changes as MindFolio reserves the right, at its discretion, to change, modify, add, or remove portions of the Privacy & Cookies Policy, and the website at any time. Your continued use of the website following the posting of any changes to this Policy will mean that you accept such changes.
11. Other Websites
This website and other Services may contain links to other third party websites. MindFolio is not responsible for the privacy policies, content or practices of such third-party websites.
12. Your rights
Some of you (in particular, European) have certain legal rights to obtain information about whether we hold personal information about you, to access personal information we hold about you, and to obtain its correction, update, amendment or deletion in appropriate circumstances. Some of these rights may be subject to some exceptions or limitations. We will respond to your request to exercise these rights within a reasonable time (and in all cases within 30 days of receiving a request).
Rights which you are entitled to are:
- Data access rights
- Right to restrict processing
- Right of Rectification
- Right to Erasure (Right to be Forgotten)
- Right to object to processing
- Right to withdraw consent; and
- Data portability rights
Where you have visited our website and you want to exercise any of the above rights please contact privacy@mindfolio.com. Alternatively, if your request is for the right to be forgotten and it relates only to our use of cookies, you can achieve this by clearing the cookies in your browser settings.
13. Exercising your rights
Our Contact Information for Privacy Inquiries: Privacy Department
MindFolio Ltd
22 Old Brewery Lane
Henley-on-Thames
Oxfordshire
RG9 2DE
UK
privacy@mindfolio.com
Complaints
If you are resident in the European Union and you are dissatisfied with how we have managed a complaint you have submitted to us, you are entitled to contact your local data protection supervisory authority. As MindFolio Ltd operates its business in the UK, it operates under the remit of the Information Commissioner’s Office.
(https://ico.org.uk/make-a-complaint/).